{"operation":"document","citation":"PI-04-0103","title":"Northern Border Pipeline Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-04-05","effective_on":null,"summary":"PI-04-0103 response to Northern Border Pipeline Company concerning 192.625.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0103.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0103.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0103","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2004/g04-04-05_de_la_Fuente_192.625-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-04-0103\nMr. Jose L. de la Fuente\nPipeline Integrity Program Management\nNorthern Border Pipeline Company\nP.O. Box 542500\nOmaha, NE 68154-8500\nDear Mr. de la Fuente:\nThis is in response to your letter of March 23, 2004, in which you request an interpretation of the\nprovisions of the Federal gas pipeline safety regulations at 49 CFR 192.625(b)(1), which requires odorization\nof gas in a transmission line in a Class 3 or Class 4 location unless \"at least 50 percent of the length of the\nline downstream from that location is in a Class 1 or Class 2 location.\"\nYou note that Northern Border Pipeline Company (NBPL) owns only the first 2.7 miles (more than\n50% Class 3) of a continuous 86.3 mile pipeline segment serving an underground gas storage facility. The\nremaining 84 miles of the line is owned by Peoples Gas Light and Coke Company (Peoples) and is\npredominately Class 1. The question is whether odorization is required in the NBPL portion of this pipeline\nbecause more than 50% of the NBPL-owned pipeline is in a Class 3 location.\nThe odorization requirements of § 192.625 are not dependent on pipeline ownership— which can\nchange— but rather on the configuration and operations of a pipeline segment, which will remain relatively\nfixed. NBPL would not have to odorize gas in the 2.7 mile segment because it is an integral part of an 86.3\nmile line to a gas storage facility. If this line were under a single ownership, it is clear that odorization would\nnot be required, and there is no reason to make odorization dependent on ownership\nTherefore, odorization is not required by § 192.625 if at least 50 percent of the ENTIRE line\ndownstream from a Class 3 or Class 4 location is in a Class 1 or Class 2 location.\nIf you have any further questions about the pipeline safety regulations, please contact me at (202)\n366-4565.\nSincerely,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nNorthern Border Pipeline Company\nP.O. Box 542500\nOmaha, NE 68154-8500\nMarch 23, 2004\nRichard D. Huriaux, (DPS-10)\nOffice of Pipeline Safety\nResearch and Special Programs Administration\nU.S. Department of Transportation\n400 Seventh Street. S.W., Rm. 7128\nWashington D.C. 20590-0001\nRe: Request for Interpretation of §192.625 (b)(1) Odorization of Gas.\nDear Mr. Huriaux:\nThis request is submitted by Northern Plains Natural Gas Company (\"NPNG\"), the operator of the Northern\nBorder Pipeline Company (\"NBPL\"), in accordance with the expressed desire of your office to address this issue\nin this manner.\nBACKGROUND INFORMATION\nThe NBPL system consists of 1,396 miles of large diameter pipeline (42-inch, 36-inch, and 30-inch OD) that\noriginates at the Canadian Border and terminates at a point near North Hayden, Indiana. This pipeline\ntransports a large volume of natural gas through the states of Montana, North Dakota, South Dakota,\nMinnesota, Iowa, and Illinois to markets in the Midwest, including the Peoples Manlove Gas Storage Field in\nIllinois, which in turn supplies natural gas to LDCs serving the Chicago area. A portion of the natural gas is\ntransported to the Manlove Storage Field through one continuous 86.7-mile OP-Ririe— segment. The first 2.7-\nmile portion of the segment is owned by NBPL, and the remaining 84-mile portion is owned by Peoples Gas\nLight and Coke Company (\"Peoples Gas\").\nOdorization issues under § 192.625 have not previously been relevant for review. Questions regarding\nodorization surfaced. However, when a fall 2003 encroachment added Class 3 feet to the 2.7-mile portion\nowned by NBPL. Issues arise only if the 86.7- mile segment would be arbitrarily separated by a demarcation of\nownership rather than by service.\nSpecifically, until the recent encroachment in fall of 2003, roughly 7400 feet at various points in the first 2.7\nmiles of the pipeline segment were Class 3. The encroachment added an additional 2600 feet of Class 3. The\nremainder of the segment traveling the 84 miles to the storage field is predominantly Class 1. If the pipeline\nsegment were viewed strictly by ownership demarcation, i.e., the 2.7-mile section owned by NBPL viewed\nseparately from the 84-mile section owned by Peoples Gas, the recent encroachment could lead to a\nconclusion that the location classification of the 2.7 mile section owned by NBPL would exceed the 50 percent\nClass 3 limit set forth in the § 192.625 (b). The remaining length of Class 1 and 2 location of the 2.7-mile\nsection downstream of Class 3 portion would be less than 50 percent. However, ownership is not listed in the\nregulations as a basis for determining a requirement for odorization. In function, and with a focus on the\nnatural gas stream, the 84-mile length of predominantly Class 1 pipeline downstream of the Class 3 location is\nin fact a continuation of the transportation system, notwithstanding ownership. Accordingly, only a very small\nfraction, approximately 3% of the pipeline downstream from the beginning of the Class 3 location, is Class 3.\nNPNG believes this is both the intended and the appropriate application of the regulation (§192.625(b)(1)).\nThe requirement for odorization should not reasonably be dependent on pipeline ownership, which can\n\n<<<PAGE 3>>>\n\nchange arbitrarily, but rather on configuration and operational function, which remain fixed with the physical\nsystem. Therefore, odorization should not be required. Otherwise requiring odorization would appear\narbitrarily linked to variable ownership positions, which could change depending on transfer of interest.\nAn interpretation of the regulation focusing on the natural gas transported in the continuous pipeline segment\nwould be entirely consistent with pipeline safety and associated regulations. NPNG therefore respectfully\nrequests your concurrence that the regulation does not require odorization in this particular situation.\nShould you have any questions or need additional information regarding this matter, please contact me\ndirectly at the number below.\nVery truly yours,\nJose L. de la Fuente\nPipeline Integrity Program Management\nPhone: (713) 345-7216","truncated":false,"body_characters":6090}